Jail Time Found to be Reasonable Condition

In State of Minnesota vs. David Steven Moody, the Minnesota Court of Appeals upheld the district court’s imposition of jail time for a Defendant who had no prior criminal record.

Defendant David Steven Moody entered into an agreement whereby he would receive a stay of adjudication of his guilty plea to a fifth-degree controlled substance possession charge. Under the terms of the agreement the State agreed to limit its jail recommendation to 45 days. The district court stayed adjudication of Moody’s guilty plea and placed him on probation for 5 years. As a condition of probation, the district court also ordered Moody to serve 45 days in jail. Moody appealed the district court’s order that he serve jail time.

A stay of adjudication is an arrangement where the defendant pleads guilty to an offense, but the Court does not accept the guilty plea. The defendant will be given certain conditions he or she must comply with during a set time period. If the defendant successfully complies with all the conditions imposed, the Court will discharge the defendant and dismiss the charge(s). A stay of adjudication essentially allows a defendant to work toward keeping the charged offense off of his or her record. If the defendant fails to comply with the conditions set, the charged offense may be entered on his or her criminal record as a conviction.

Moody’s challenged the district court’s order that he serve jail time on the basis that the district court had no authority to order jail time as a condition of probation because there was no conviction. Moody also challenged the order for jail time on the basis that imposing jail time was unreasonable because he had no prior criminal record and was amendable to probation.

The Court of Appeals upheld the district court’s order for jail time finding that the statute allowing for a stay of adjudication, Minn. Stat. § 152.18, does not prohibit jail as a condition of the stay. In addition, the Court of Appeals found that the district court is allowed to set “reasonable conditions,” and even though Moody did not have any prior criminal record, the jail time was reasonable in light of the severity of the charges. The Court of Appeals was not hesitant to point out that Moody had agreed to the State asking for a 45 day cap of the jail time, too.

Criminal convictions can have lifelong collateral effects on a person’s professional licensing, employment and housing. To ensure that your rights are protected, contact a Minneapolis Criminal Defense attorney today.

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